16 RUBINS v. LATVIA JUDGMENT Nenkova-Lalova v. Bulgaria, no. 35745/05, § 60, 11 December 2012). In applying the above principles to the present case the Government emphasised that the impugned email had contained personal threats directed against the Rector and that the applicant had been well aware of the unlawfulness of the proposals made in the email. Moreover, according to the Government, the contested email did not fall within the scope of a public debate, as the applicant had been guided by a personal desire not to lose his job. The Government stressed that the domestic court and the prosecutor’s office had come to the same conclusion, namely that the email demonstrated bad faith on the part of the applicant. 64. The Government also considered the sanction imposed on the applicant to have been proportionate and pointed out that after his dismissal the applicant had not been prevented from pursuing his professional activities both in a professional organisation and in another major university. Moreover, in 2012 the criminal proceedings initiated against the applicant had been terminated. 65. The Government also produced a letter in which the University provided replies to the Government’s questions. It stated, inter alia, that the University had assessed the question whether a less restrictive measure could be applied to the applicant and had also examined the employee’s right to freedom of expression, as attested to by the analysis of the impugned email carried out by the ethics committee and the ad hoc investigative committee. 66. Finally, reiterating the arguments employed by the Riga Regional Court (see paragraph 25 above), and referring to the principle of subsidiarity reiterated in the Palomo Sánchez judgment, the Government maintained that the domestic court had thoroughly analysed the evidence brought before it, thus rendering the sanction proportionate to the legitimate aim of protecting the reputation and dignity of those against whom the email was directed. B. The Court’s assessment 1. Whether there was “interference” with the applicant’s rights under Article 10 67. According to the Court’s case-law, in order to determine whether an applicant’s right protected under Article 10 of the Convention has been infringed it must first be ascertained whether the disputed measure amounted to interference with the exercise of freedom of expression, in the form, for example, of a “formality, condition, restriction or penalty” (see Glasenapp v. Germany, 28 August 1986, § 50, Series A no. 104, Kosiek v. Germany, 28 August 1986, § 36, Series A no. 105). 68. It is clear from the parties’ submissions that the existence of the interference is in dispute between the parties, as they are not in agreement as